EAR

Questions and answers about EAR

  • EAR BEST PRACTICES

    Question: I am currently setting up an export compliance program and would like to obtain some export compliance references to assist me and company colleagues. what is the value of buying a hardcopy of the official regulations and policies governing the export licensing of commodities and technical data? Is it not best practice to use […]

  • Form BIS-645P applicability to USML and USMIL

      Question:   Could someone please comment if Supplement No. 5 To Part 748 – U.S. Import Certificate and Delivery Verification Procedure (a)(1)(iii) still needs to be corrected since DOS published a final rule April 17th, 2012 ceasing the DOS’s practice of accepting DSP–53 submissions (Amendment to the ITAR: International Import Certificate BIS–645P/ATF–4522/DSP–53 and Administrative […]

  • RISK FOR COURIER SHIPMENTS

      Question:   We sell all EAR99 products. For smaller export shipments, our company has   used couriers in the past. What are our risks in this approach? How do   couriers handle EEI filings?   **********

  • EAR99 FDA export restrictions to Afganistan

    Question: If we need to ship EAR99 medical/dental supplies to Afghanistan for use by US forces, are there any FDA export restrictions? (Examples: IV drip bag stands, metal scrapers, picks, etc. used in dental work, drip lines, plastic breathing tubes, fabric surgical drape cloths.) ============

  • Question on TMP Exemption

    Question:   If we  are not sure how a single signal generator was shipped to our parent company (maybe under a dsp 5, or no license under EAR) and it needs to be sent to US for repair,  are we allowed to  use the 123.4a.1 exemption under ITAR ?   Or are we only allowed […]

  • ACQUISITION LIABILITY

    Question: Our company just purchased the patents and assets of another company(they keep their tax id).  We are in the process of evaluating andclassifying their products for import/export, and they will begin usingour tax id’s for their limited import and export transactions as theyare migrated to our system, but I want to make sure I […]

  • EAR LICENSE EXCEPTION GOV

    Question: If something originally exported via license exception GOV and comesback for service/repair, does it ship back out under license exceptionGOV to the governmental agency or license exception RPL? Where in theEAR can I find this information?

  • SANCTIONED PARTIES AS END USERS

    Question: We have a subsidiary company in China actively selling our EAR99 product.   They have recently found a customer in China that appears to be set up as an   import/export company and they want us to ship to multiple ports throughout China.   Searching the company on the internet, I find they have been named […]

  • NOTIFYING CUSTOMERS OF EXPORT LICENSE REQUIREMENTS

    Question:   For those of you who may sell a product that requires an export license to ship to a large number of countries (for example, National Security, Column 2), do any of you include any notice with the shipped product, when selling to a customer in a country that doesn’t require an export license, […]

  • EXPORT CONTROL FOR DISTRIBUTORS

    What is the shipper’s obligation concerning export control with their distributors (domestic & International) on sending an EAR99 shipment? Do you ask your distributor for the end-user? Can the membership please share their process they have in place concerning distributors.